Realigning targets and practices for effective e-waste management

Executive summary

DIGITALEUROPE members are leading innovation in electrical and electronic equipment (EEE). However, the rising environmental challenges related to the management of waste electrical and electronic equipment (WEEE) demand modern solutions that can keep up with technological advancements.

This paper provides key recommendations for revising the WEEE Directive,¹ ensuring it remains fit for purpose in supporting sustainability goals whilst addressing practical industry realities. Our key recommendations are to:

• Shift to a collection target based on WEEE available for collection: The current 65 per cent target, based on EEE placed on the market (POM) over the previous three years, does not account for the longer lifecycles of modern EEE products, nor the second-hand market. We recommend moving towards a target that better reflects actual WEEE generation, leveraging the WEEE calculation tool already developed by the Commission. This tool should be further refined to consider product lifespans, unofficial collections and legal exports for reuse.
• Establish an EU-harmonised methodology: A centralised, harmonised methodology for calculating WEEE available for collection will ensure consistent and fair target setting across Member States. By aligning the WEEE Directive with broader EU regulations like the Ecodesign for Sustainable Products Regulation (ESPR),² the EU can create a cohesive system that encourages environmental responsibility and compliance.
• Oblige all actors to report on WEEE collection: The ‘all actors’ principle is crucial for ensuring transparency and accountability across the entire WEEE management chain. All entities involved in handling WEEE – producers, recyclers, refurbishers and others – must be legally required to report the volumes they manage, preventing unofficial streams from escaping proper recycling and recovery systems.
• Set minimum logistics and treatment standards: Harmonised standards for WEEE collection, transportation and treatment, aligned with CENELEC guidelines, are essential to ensure high-quality recycling and a reduction in dependency on virgin raw materials. This would also enhance the recovery of secondary raw materials, critical for the EU’s circular economy.
• Re-examine WEEE categories for greater precision: Current WEEE categories do not adequately reflect the diverse lifespans and technical characteristics of various EEE types. More granular categories, particularly within large equipment, will enable tailored collection targets and more efficient waste management.
• Streamline reporting requirements: Reporting obligations should be harmonised across the EU to eliminate unnecessary burdens on producers and enhance the comparability of data. A standardised WEEE reporting template would reduce administrative complexity and improve data quality.
• Adopt digital labelling to replace the crossed-out wheelie bin: The outdated crossed-out wheelie bin symbol should be replaced with digital labelling, such as QR codes, providing consumers with actionable information on how to recycle their products.
• Prohibit WEEE fee eco-modulation and visibility: National schemes that introduce WEEE fee eco-modulation lack harmonisation and create market distortions. Such practices should be prohibited as should the visibility of WEEE fees for ICT products, which adds unnecessary administrative burden without demonstrable environmental benefits.
• Maintain open scope but careful product allocation: The current ‘open scope’ should be maintained, ensuring that innovative products are carefully assigned to existing or new EEE categories without expanding the scope unnecessarily.
• Avoid new product design requirements: The revision should not introduce additional product design requirements, which are already covered by the current and future ecodesign regulations. This will prevent regulatory overlap and confusion whilst focusing the WEEE Directive on its core aim of improving waste management.

By incorporating these changes, the revised WEEE Directive can better reflect current technological realities, drive sustainable waste management practices, and support the EU’s broader environmental objectives without creating undue burdens on industry stakeholders.